Memorandum of Support
A.2816 (Jones), S.3030 (Stec)
Click here to download a PDF of the support memo.

The Preservation League of New York State is the statewide historic preservation nonprofit. We lead advocacy, economic development and education programs across the state. We write in support of Bill A.2816 (Jones) / S.3030 (Stec), which propose amending the New York State Constitution to convey land to Debar Pond Institute in order to save the historic Debar Pond Lodge.

A.2816 / S.3030 propose a land exchange in the Adirondack Park between New York State and Debar Pond Institute (“The Institute”), a private, non-for-profit educational organization. The Institute will operate Debar Pond Lodge and the six-acre parcel on which it sits for educational and recreational purposes. In exchange for the six-acre parcel, The Institute will donate over 400 acres of land to expand the Adirondack Forest Preserve. This land exchange will be accomplished at no cost to New York State taxpayers, and will save the state the cost of demolishing the lodge and redeveloping the property.

A.2816 / S.3030 will allow the historic lodge to be retained and used for public education and recreation. It will also increase the acreage of the Adirondack Forest Preserve by over 400 acres.

Debar Pond Lodge is an outstanding example of traditional Adirondack architecture, designed by noted local architect William Distin. It was listed in the National Register of Historic Places in 2014. This legislation will ensure that the historic Lodge and the property on which it sits will be available to the public in perpetuity. As a condition of the land exchange, a conservation easement will be attached to the property which will require that the Lodge and other buildings be well preserved, used in the public interest, and available for public access. Among the public activities the Debar Pond Institute plans to implement are public tours, programming on Adirondack history, culture, and the environment, as well as programs that advance diversity in the Adirondacks. The boundaries of the Debar parcel have been drawn to guarantee continued public access to the shoreline of Debar Pond as well as the hiking trail around Debar Pond and on to Debar Mountain.

We urge the NYS Assembly and Senate to adopt A.2816/S/3030. This bill will help preserve a magnificent example of Adirondack architecture, increase the Adirondack Forest Preserve by over 400 acres, and create an outstanding new opportunity for public use that will provide valuable new opportunities to Adirondack residents and visitors. Thank you to Assemblymember Jones and Senator Stec for their leadership.

Memorandum of Support
A.4030 (Barrett), S.3582 (Hinchey)
Click here for a PDF of this letter.

The Preservation League of New York State is New York’s statewide historic preservation nonprofit organization. We lead advocacy, economic development and education programs across the state and partner with local preservation organizations throughout New York. Together with our local and regional partners listed below, we strongly support of Bill A.4030 (Barrett) / S.3582 (Hinchey), which propose adding a refundability provision to the state’s Historic Barn Rehabilitation Tax Credit program, providing New Yorkers with an income below $60,000 with a refund for excess tax credits from the rehabilitation of historic barns.

The 25% Historic Barn Rehabilitation Tax Credit, launched in 2022, promotes barn rehabilitation, vital in retaining remaining historic barns in every corner of the state. Not only does the existence of this program pay homage to New York’s agricultural history and architecture, it also supports thoughtful reuse, community enjoyment, and the elimination of landscape decay, while avoiding the negative environmental impacts of demolition.

From the launch of the program in the spring of 2022 through the end of the calendar year, the NYS Office of Parks, Recreation and Historic Preservation received over 60 applications from owners wishing to take advantage of the credits to either retain their barns in agricultural use, or adaptively reuse them for other commercial (non-housing) purposes.

While the program is seeing robust use by those with sufficient income to take advantage of the 25% credit, some barn owners do not have sufficient income to allow them to take advantage of the credit. Bill A.4030/S. 3582, modeled after a similar provision in the state’s Homeowner Rehabilitation Tax Credit program, offers a rebate to those whose incomes are below $60,000. We strongly support these bills that make the credit more equitable by making it available to small farmers and other barn owners who are investing in the repair and rehabilitation of their barns but cannot now use the credit.

We thank Assemblymember Barrett and Senator Hinchey for their leadership in sponsoring the bills that created the current Historic Barn Rehabilitation Tax Credit, and for sponsoring the current bills to make this important adjustment to the program.

Supporting Organizations

Memorandum of Support A.2889 (Woerner) and S.4174 (Kennedy)
Click here to download this document as a PDF

The Preservation League of New York State is New York State’s statewide historic preservation nonprofit. We lead advocacy, economic development and education programs across the state and partner with local preservation organizations throughout New York. We write in support of Bill A.2889 (Woerner) and S.4174 (Kennedy) relating to extending the NYS Historic Rehabilitation Tax Credit programs and improving their functionality for the rehabilitation of large, long-vacant buildings. We urge the Assembly and Senate to include these provisions in their budget bills this March. These improvements will facilitate the return of large vacant buildings such as warehouses, rail terminals, and mill complexes to productive use. The bills provide additional enhancements to prioritize rehabilitation projects incorporating affordable housing.

The State Historic Tax Credit program is a critical tool for sustainable, environmentally friendly development that keeps valuable building materials out of landfills, strengthens existing walkable communities, reduces greenfield development, and recaptures embodied energy. It is also a highly effective tool for housing creation: since 2010, the state tax credits have been responsible for the creation of 21,929 housing units, 8,542 of which are low/moderate income units.

The NYS Historic Tax Credit programs are currently set to sunset on December 31, 2024. The improvements outlined in A.2889 and S.4174 include a 10-year extension of the program, until December 31, 2034. Since their inception, the credits have been extended in five-year increments; given the current construction climate, and in particular the lead time inherent in affordable-housing rehabilitation projects, a ten-year extension would help give building owners the confidence that the program will still be available when they are ready to move forward. We strongly support this longer extension.

The bills also propose enhancements aimed at facilitating reuse of large, long-vacant buildings. “White Elephants” are defined in the bill as buildings that have been vacant for at least 10 of the last 15 years, with rehab costs of $50 million or more. For all projects meeting these “white elephant” criteria, the proposed enhancements are: 1) raise the commercial credit cap from $5 million to $15 million, and 2) bifurcate the state and federal credits to allow them to be used by separate entities. For “white elephant” projects incorporating affordable housing, the bill proposes two additional enhancements: 1) make the credits transferable to investors outside the development partnership, and 2) make them available statewide, facilitating the creation of affordable housing outside qualifying census tracts, which would help create affordable housing in low poverty areas. Bifurcation and transferability are important enhancements that would expand the pool of investors and bring more equity into these projects at no additional cost to the state.

The League strongly supports the two bills, and we urge the Senate and Assembly to include them in the FY 2024 NYS budget to support sustainable economic development and affordable housing using our existing building stock.

The Unmarked Burial Site Protection Act (S5701 / A6724) was passed by both the NYS Senate and Assembly earlier this year. This legislation is long overdue and the League strongly encourages the Governor to sign it into law. If she does not sign the bill before December 31, 2022, it will be effectively vetoed. For more about this issue, please also follow the Shinnecock Graves Protection Warrior Society, who have led much of the advocacy around this topic on Long Island.

December 1, 2022

The Honorable Kathy Hochul
Governor of New York State
NYS Capitol Building
Albany, NY 12224

Dear Governor Hochul,

On behalf of the Preservation League of New York State, I write to urge you to sign the Unmarked Burial Site Protection Act, which provides important protections for human remains in unmarked burial sites across the state that are in danger of damage from construction and other disruptions.

New York is one of only three states that lack statewide protection for unmarked burial sites. In recent years, graves associated with Native American Nations, African American communities, and Revolutionary War soldiers have been discovered during construction or development. In the absence of clear legal protocols, the human remains in these sites have lacked protection from desecration and destruction, as do those in other such sites yet to be discovered. The Unmarked Burial Site Protection Act will finally establish a clear legal process to protect human remains discovered during construction, by requiring that these sites and remains are treated with respect, the proper authorities are notified, and the remains are ultimately handled in an appropriate way. 

The League strongly encourages you to sign this important legislation.

Sincerely,

Katie Eggers Comeau
Vice President for Policy and Preservation

Click here for a PDF of this support letter.

November 17, 2022

Supervisor Peter Van Scoyoc and Members of the Town Board
Town of East Hampton
159 Pantigo Road
East Hampton, New York 11937

Dear Supervisor Van Scoyoc and Members of the East Hampton Town Board,

Preservation Long Island, the Preservation League of New York State, and the National Trust for Historic Preservation, the leading historic preservation advocacy organizations at the regional, state, and national levels, have all identified the James Brooks and Charlotte Park Studios and Residence as a top priority for preservation and rehabilitation due to the property’s exceptional significance in the history of mid-century modern art and design. The buildings used and occupied by Charlotte Park and James Brooks represent a unique opportunity to celebrate their legacy for the benefit of East Hampton residents and visitors, connecting their lives and careers to a broader culture of artistic achievement in this part of Long Island. In 2021, Preservation Long Island listed the site in its Endangered Historic Places List; the National Trust similarly included it on its the “Eleven Most Endangered Places” list in 2022; and the Preservation League named the site one of its “Seven to Save” properties in 2022.

We continue to express our concern for the buildings’ condition if they remain poorly maintained, and urge, in the strongest possible terms, the Town of East Hampton to take swift and significant steps to stabilize and protect the Brooks-Park Studios and Residence ahead of the 2022-23 winter season to prevent further damage, particularly due to water infiltration.

We know full well that their current unprotected status is not due to a funding constraint, but a deficit of political will. The Town has the authority – in fact, the obligation – as well as the funding necessary to stabilize the buildings, and to hire a consulting preservation architect qualified to conduct a thorough assessment of the buildings’ condition and the feasibility of rehabilitation. In § 112-1-50A[4], the East Hampton Town Code requires the Town to “manage and maintain historic properties consistent with accepted standards for historic preservation” (see also § 64-E.9[d] of the enabling New York Town Law). In regard to hiring a consulting preservation architect, please see § 64- E.13 of the enabling New York Town Law for the Peconic Bay Region Community Preservation Fund, which explicitly permits expenditure of fund monies for “cost of employees and independent contractors to implement the provisions of this section.”

Preservation Long Island, the Preservation League of New York State, and the National Trust for Historic Preservation encourage the Town of East Hampton to treat the Brooks-Park Historic Landmark as the treasure that it is, a place that tells the stories of James Brooks and Charlotte Park and their contributions to the development of Abstract Expressionism, as well as an opportunity to celebrate the extraordinary artistic heritage of the Springs. Given the property’s historic significance and cultural importance, we urge the Town of East Hampton to secure the site.

Our collective lenses are focused on preserving this unique, irreplaceable cultural and historic heritage site. Further neglect is the least attractive and most unpopular option. We will follow up in 30 days and eagerly await news of your action.

Sincerely,

Seri Worden
Senior Field Director, National Trust for Historic Preservation

Sarah Kautz
Preservation Director, Preservation Long Island

Katie Eggers Comeau
VP for Policy and Preservation, Preservation League of NYS

Local advocates in Schenectady, led by our colleagues at Schenectady Heritage Foundation, are currently lobbying for historic overlay zoning of the 1918 Masonic Temple. Located on the corner of State Street and Erie Blvd, the building occupies a prominent location in Schenectady’s Downtown district — a neighborhood included on the League’s Seven to Save list back in 2000. The League’s VP for Policy & Preservation Katie Comeau submitted the following letter to the Schenectady Planning Commission in support of the local historic designation of the former Masonic Temple.

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To: Planning Commission, City of Schenectady Department of Development
Schenectady City Hall, 105 Jay Street Schenectady, NY 12305

Dear Commissioners:

On behalf of the Preservation League of New York State, I am writing in support of the local historic designation of the former Masonic Temple at the intersection of State Street and Erie Boulevard. This building has been determined eligible for the State and National Registers of Historic Places “as an excellent local example of an early twentieth century Neoclassical commercial building,” and meets the criteria for local landmark designation as well.

Constructed in 1912 as retail and showroom space for a local furniture store, the building was remodeled several years later to serve as a Masonic temple. Its historic association with the local Masonic organization, as well as its architectural significance and visual prominence, all contribute to its significance and worthiness for landmark status.

At the League, we support efforts by local preservation advocates and municipal preservation boards to designate and protect historic buildings, districts, and landscapes that are important to their communities. Retention and reuse of historic buildings is beneficial to community character, economic revitalization, and environmental sustainability. We encourage the Planning Commission to recommend inclusion of this building in the OH Overlay Historic District.

Sincerely,

Katie Eggers Comeau
Vice President for Policy and Preservation, Preservation League of NYS

Penn Station needs to be improved, but the current Penn Area Plan is not the answer. Join us in speaking out against it!

What's at stake

The League included the Penn Area Neighborhood on our Seven to Save list because Empire State Development's (ESD) proposed Penn Area redevelopment plan would demolish multiple city blocks, including over 40 historic buildings and structures, displacing thousands of residents and businesses. The negative environmental impact of this needless demolition would be a catastrophe. The plan itself raises numerous, serious questions that have yet to be answered, especially regarding how the project will be paid for. The lack of transparency is an insult to locals, and this kind of top-down governmental overreach poses a threat to communities across the state — not just our largest city.

Click here to read an open letter to Governor Hochul from League President Jay DiLorenzo.

What can you do? 

From our colleagues at Human-Scale NYC and the Empire Station Coalition:

Write to the Public Authorities Control Board and tell them to reject the General Project Plan for Penn Station. It is fiscally irresponsible and puts taxpayers statewide on the hook for an unknowable amount of money. This is contrary to the public interest. The project speculates on a revenue stream that might never come to fruition after what Empire State Development says will be a 22-year build out of supertall office towers by Vornado. This project does nothing for transit efficiency. Instead of doing real economic development, this project merely turns our government into a real estate speculator.

Write or call the members of the Public Authorities Control Board today:

• Assemblywoman Amy Paulin: PaulinA@nyassembly.gov

• Senator Leroy Comrie: comrie@nysenate.gov

• Assemblyman Joseph M. Giglio: GiglioJ@nyassembly.gov 

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Empire Station Coalition is a group of concerned community organizations led by co-coordinators Sam Turvey of RethinkNYC and Lynn Ellsworth of Human-Scale NYC, who banded together in 2020 to fight the Penn Area Plan. ESC has worked tirelessly to push the Plan's many flaws to the forefront of public attention.

In this open letter to Governor Kathy Hochul, League President Jay DiLorenzo urges her to use her authority to halt Empire State Development’s planned approval of the Penn Station Area project on July 21. The League included the Penn Area Neighborhood on our Seven to Save list because that plan would demolish multiple city blocks, including over 40 historic buildings and structures, displacing thousands of residents and businesses. The negative environmental impact of this needless demolition would be a catastrophe. The plan itself raises numerous, serious questions that have yet to be answered. The lack of transparency is an insult to locals, and this kind of top-down governmental overreach poses a threat to communities across the state — not just our largest city.

Penn Station needs to be improved, but the current plan is not the answer. Join us in demanding that Governor Hochul put a stop to Empire State Development’s planned approval on July 21!

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July 15, 2022

The Honorable Kathy Hochul
Governor of New York State
NYS State Capitol Building
Albany, NY 12224

Dear Governor Hochul,

The Preservation League of New York State respectfully asks that you use your authority as Governor to delay Empire State Development Corporation’s planned approval of the Penn Station area project, currently scheduled for July 21. 

The plan raises numerous, serious questions about its viability that have not been addressed, including how it will be financed, and what will happen if, especially given the weak demand for office space in a pandemic and post-pandemic world, the expected revenue does not materialize. Even if all those questions could be answered, the plan would still represent a colossal waste of resources, energy, irreplaceable architecture, and building materials.

The Empire State Development Corporation’s proposed Pennsylvania Station Civic and Land Use Project (the "Penn Area Plan") represents an unfortunate return to the Urban Renewal mindset of the mid-20th century, which promised that large-scale demolition would somehow lead to more viable and vibrant cities. Cities throughout the state and nation bear witness to the devastation caused by speculative demolition without a feasible rebuilding plan. Thousands of irreplaceable historic resources – of which the original Penn Station is an iconic example – were lost and wastefully discarded. Governor Hochul, we urge you to avoid repeating the mistakes of the past by halting this ill-conceived plan.

The current Penn Station is, without doubt, in need of improvement, and the League has no objection to upgrades that will improve the station’s functionality and aesthetics. What we strongly oppose is the plan to demolish multiple blocks of historic buildings in the vicinity of the station in the hope that private redevelopment will raise revenue for station improvements. We also oppose the opaque and top-down planning approach, which has utterly lacked the transparency and respect for local land-use procedures we thought the current administration championed.

All told, over 40 historic buildings and structures stand to be lost while displacing thousands of residents and businesses. The immediate impact on the people who live and work in this neighborhood would be devastating. The needless demolition is an environmental catastrophe. The negative environmental impact related to the embodied carbon that is wasted when buildings are demolished and put in a landfill, combined with the carbon output of major new construction projects, is in direct opposition to New York State’s proclaimed climate action goals. It is for these reasons that the Preservation League included the Penn Neighborhood on our current Seven to Save list of endangered historic places – underscoring the magnitude of the threat this community faces given the proposed Penn Area Plan. 

Penn Station needs to be improved, but the current Penn Area Plan is not the answer. The people of New York deserve better. Along with our New York City-based colleagues at the New York Landmarks Conservancy and the grassroots activists of the Empire Station Coalition, the League strongly urges Governor Hochul to put a stop to Empire State Development’s planned approval on July 21.

Sincerely,

Jay DiLorenzo
President, Preservation League of NYS

Click here for a PDF of this letter.

The proposed South of Union Square Historic District is one of this year’s Seven to Save. This neighborhood in Manhattan boasts a wide variety of of building types, many of which have ties to important social and cultural movements. Our colleagues at Village Preservation have been pushing for landmark designation and zoning protections to preserve the area’s historic character, limit out-of-scale construction, and prevent needless demolition. The League’s Vice President for Policy & Preservation Katie Comeau recently submitted a public letter of support for these efforts.

“We recognize that no historic district, whether in Manhattan or anywhere else in New York State, can or should be frozen in time. Change defines this and other Manhattan neighborhoods and will continue to do so. As you know, historic district designation does not and should not prevent all change, but provides a mechanism for managing change in a way that is respectful of the history and character of the district, balances competing concerns, and does not cede control over the process to aggressive development interests.

On behalf of the Preservation League, I urge you to support the designation of the proposed South of Union Square Historic District.”

Click here to read the full letter.

Through the recent inclusion of the James Brooks-Charlotte Park Home and Studios on the 2022-2023 Seven to Save list, the League is working alongside local advocates as well as colleagues at Preservation Long Island and the National Trust for Historic Preservation to advocate for the protection of this important historic site. As the East Hampton Town Council deliberates over how to proceed with the Brooks-Park site, VP for Policy and Preservation Katie Comeau sent a letter of support to East Hampton Town Supervisor Peter Van Scoyoc and members of the Town Council to publicly and explicitly encourage the Town to preserve the site and all four buildings on its grounds. As Katie details in her letter, “Our Seven to Save selection committee was impressed by the Brooks-Park property due to its unique architectural and historical significance and its potential to be both a recreational and historical asset to the town of East Hampton. The committee was equally impressed by the passion of local advocates and their vision for the future of the property as an artistic and environmental sanctuary. Charlotte Park and James Brooks drew inspiration from the natural world while in their home and studios; those who visit today can similarly immerse themselves in nature while also experiencing and learning about the artists’ contributions to Abstract Expressionism and their place in the remarkable Long Island art community in the mid-twentieth century.”

Click here to read the full support letter.